oversight

Muskegon Heights Housing Comm., Muskegon Heights, MI

Published by the Department of Housing and Urban Development, Office of Inspector General on 1996-10-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                                   Issue Date

                                                                        October 29, 1996
                                                                   Audit Case Number

                                                                        97-CH-202-1002




TO:           Lindsey S. Reames, Director, Public Housing Division, Grand Rapids
             Area Office


FROM:         Dale L. Chouteau, District Inspector General for Audit, Midwest

SUBJECT:      Muskegon Heights Housing Commission
              Low-Income Housing Program
              Muskegon Heights, Michigan

We completed an audit of the Muskegon Heights Housing Commission's Low-Income Housing
Program. We selected the Commission for audit based on a program of periodic reviews of
public housing authorities and input from the Grand Rapids HUD staff. The audit objectives
were to determine whether the Commission effectively and efficiently administered its low-
income public housing activities in compliance with HUD's requirements.

We found the Commission generally administered its Low-Income Housing Program according
to HUD's requirements. The Commission maintained its occupied units in decent, safe and
sanitary condition; and properly maintained its accounts receivable balances and occupancy
levels. The Commission, however, could improve its operations by: (1) following the terms of
its Vacancy Reduction Program agreement, (2) assuring that the tenant eviction process is
economical and the provider of the services is selected using full and open competition; (3)
submitting independent audits, operating budgets, and other financial information reports to HUD
timely; and (4) establishing proper controls over its non-expendable assets.

Within 60 days, please provide us, for each recommendation made in this report, a status report
on: (1) the corrective action taken; (2) the proposed corrective action and the date to be
completed; or (3) why action is considered unnecessary. Also please furnish us copies of any
correspondence or directives issued because of the audit.

Should your staff have any questions, please have them contact me at (312) 353-7832.
Management Memorandum




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97-CH-202-1002                   Page ii
Executive Summary
We conducted an audit of the Muskegon Heights Housing Commission's Low-Income Housing
Program. Our objectives were to determine whether the Commission effectively and efficiently
administered its low-income housing activities in compliance with HUD's requirements.

We found the Commission generally administered its Low-Income Housing Program according
to HUD's requirements. The Commission maintained its occupied units in decent, safe and
sanitary condition; and properly maintained its accounts receivable balances and occupancy
levels. However, as shown in our findings, the Commission could improve the administration
of its Low-Income Housing Program by adhering to HUD's requirements for the Vacancy
Reduction Program, the tenant eviction process, submission of financial information, and control
of non-expendable assets.



                                    The Muskegon Heights Housing Commission overstated its
 The Commission Did Not
                                    repair fund requirements in its Vacancy Reduction Program
 Follow Its Vacancy
                                    application and did not complete all planned management
 Reduction Program
                                    improvement items or any lead based paint abatement. The
                                    Director said he did not fully understand the program. As
                                    a result, the Commission violated the terms of its agreement
                                    with HUD and the Commission has not started its required
                                    lead based paint abatement program.

                                    The Muskegon Heights Housing Commission paid
 The Commission's Tenant
                                    unnecessary amounts to a legal firm for tenant eviction
 Eviction Process Was Not
                                    services. The Commission paid the firm to perform some
 Economical
                                    services that should have been done by the Commission's
                                    staff.    Additionally, the Commission did not have
                                    documentation to support its procurement of eviction legal
                                    services. As a result, the Commission was not making the
                                    best use of its resources and HUD and the Commission lack
                                    assurance full and open competition was used to select the
                                    provider of the eviction services.

                                    The Muskegon Heights Housing Commission did not
 The Commission Did Not
                                    submit its independent audits, operating budgets, and other
 Submit Financial
                                    financial information reports to HUD timely. As a result,
 Information Timely
                                    HUD did not have adequate information to assess the
                                    Commission's financial condition, and the Commission was
                                    prevented from withdrawing Federal funds to meet its
                                    obligations during the times it did not have an approved
                                    budget.




                                             Page iii                               97-CH-202-1002
Executive Summary



                        The Muskegon Heights Housing Commission did not
 Control Over Non-
                        follow its own inventory policy and HUD's requirements to
 Expendable Equipment
                        protect its non-expendable equipment. The Commission
 Was Not Adequate
                        did not conduct annual physical counts of its equipment and
                        supplies and did not routinely update its property records.
                        The Commission's Director said the Commission did not
                        take or reconcile inventories because he did not believe
                        inventories were important. To help detect and prevent
                        misuse or loss of resources, it is important for the Authority
                        to take annual inventories and maintain accurate records.

                        We recommend that the Director of the Public Housing
                        Division validates the reasonableness of planned vacancy
                        reduction work contained in applications submitted to HUD
                        and closely monitors the Commission to ensure that it
                        complies with HUD's lead based paint abatement
                        requirements.      We also recommend the Housing
                        Commission implements procedures and controls to assure:
                        the services performed by its legal firm for the tenant
                        eviction process are economical; financial reports are
                        prepared timely; and non-expendable equipment is properly
                        controlled.

                        We provided our draft findings to the Commission's
                        Executive Director and HUD's staff during the audit. We
                        held an exit conference on October 18, 1996 with the
                        Commission's Executive Director.         The Housing
                        Commission provided written comments to our findings.
                        We considered the comments in preparing our report. The
                        Commission's comments are included in their entirety in
                        Appendix A.




97-CH-202-1002                   Page iv
Table of Contents

Management Memorandum                                              i


Executive Summary                                                 iii


Introduction                                                       1


Findings

    1      The Commission Did Not Follow Its Vacancy
           Reduction Program                                       3

    2      The Commission's Tenant Eviction Process
           Was Not Economical                                      9

    3      The Commission Did Not Prepare Timely
           Financial Reports                                     13

    4      Control Over Non-Expendable Assets Was
           Not Adequate                                          17


Internal Controls                                                21


Follow Up On Prior Audits                                        23


Appendices

    A      Auditee Comments                                      25

    B      Distribution                                          35



                              Page v                   97-CH-202-1002
Table of Contents




97-CH-202-1002      Page vi
                                       Table of Contents




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                Page vii                     97-CH-202-1002
Introduction
We completed an audit of the Muskegon Heights Housing Commission. The Commission was
established in 1964 under the laws of the State of Michigan. The Commission is a public housing
agency organized to provide decent, safe and sanitary housing to low-income families.

A five-member Board of Commissioners governs the Housing Commission. The Mayor of the
City of Muskegon Heights appoints the board members to staggered five-year terms. The
Executive Director is responsible for the day-to-day operations of the Commission.

The Housing Commission operates and maintains 355 low-income housing units at four
developments. Columbia Courts contains 90 elderly units. East Park Manor and East Side
Courts contain 199 and 49 family units respectively. There are 17 scattered site family units.
The Commission also manages 50 Section 8 units.

For fiscal years 1994 and 1995, the Commission received $882,452 in operating subsidies and
$1,906,327 for its Comprehensive Grant Program. In 1994, HUD also approved a Vacancy
Reduction Program Grant of $445,800 and a Drug Elimination Grant of $106,500.

The Commission's books and records are at 615 E. Hovey Avenue, Muskegon Heights, Michigan.
Joe L. Mattox is the Executive Director.



                                    Our audit objectives were to determine whether the
 Audit Objectives
                                    Commission effectively and efficiently administered its
                                    Low-Income Housing Program according to HUD's
                                    requirements.

                                    Our specific objectives were to determine whether the
                                    Commission:

                                    •   Maintained decent, safe and sanitary units;

                                    •   Prepared timely financial reports;

                                    •   Properly managed its non-expendable equipment;

                                    •   Properly maintained accounts receivable balances and
                                        occupancy levels;

                                    •   Efficiently managed its tenant eviction process; and

                                    •   Managed the Vacancy Reduction Program according to
                                        its agreement with HUD.



                                             Page 1                                   97-CH-202-1002
Introduction



                   To obtain background information, we interviewed HUD's
 Audit Scope and
                   staff from the Grand Rapids Area Office's Public Housing
 Methodology
                   Division. At HUD's Grand Rapids Office, we also reviewed
                   independent audit reports, operating budgets, statements of
                   operating receipts and expenditures, and Vacancy
                   Reduction Program reports.

                   To assess the adequacy of the Commission's operations, at
                   the Commission's Office, we interviewed the Executive
                   Director and applicable staff. We also reviewed records
                   related to independent audits, budgets, financial reports
                   submitted to HUD, inventory records, the procurement
                   process used to obtain tenant eviction legal services,
                   accounts receivable and occupancy reports, and status
                   reports for the Vacancy Reduction Program. We inspected
                   five units to assess their condition.

                   The audit covered the period between June 1, 1994 and
                   May 31, 1996. We extended the audit period as necessary.
                   We did the on-site audit work between June and September
                   1996. The audit was conducted in accordance with
                   generally accepted government auditing standards.

                   We provided a copy of the report to the Executive Director
                   of the Muskegon Heights Housing Commission.




97-CH-202-1002             Page 2
                                                                                     Finding 1




 The Commission Did Not Follow Its Vacancy
       Reduction Program Agreement
The Muskegon Heights Housing Commission overstated its repair fund requirements in its
Vacancy Reduction Program application and did not complete all planned management
improvement items or any lead based paint abatement in its grant agreement. The Director said
he did not fully understand the program. As a result, the Commission violated the terms of its
agreement with HUD and the Commission has not started its required lead based paint abatement
program.



                                    Regulation 24 CFR, Section 968.422(b) states that work
 HUD's Requirements
                                    items under the Vacancy Reduction Program must be
                                    completed within two years from the date of funding, unless
                                    prior approval is obtained from HUD.

                                    Regulation 24 CFR, Section 968.110(k) requires a housing
                                    commission to test its units for lead based paint and abate
                                    the lead based paint if the tests are positive. A commission
                                    is required to prioritize the abatement program within its
                                    Comprehensive Modernization Program.

                                    The Muskegon Heights Housing Commission overstated its
 Vacancy Reduction
                                    repair fund requirements in its Vacancy Reduction Program
 Program Requirements
                                    grant application that was approved by HUD. Further the
 Were Not Completed
                                    Commission did not complete all planned work items. The
                                    Commission did not implement all of its scheduled
                                    management improvements and did not abate lead based
                                    paint in any of the scheduled 35 units as specified in its
                                    agreement.

                                    On November 11, 1994, HUD gave the Commission
                                    $445,800 for vacancy reduction efforts on 35 units. The
                                    funding included: $280,000 for repairs; $70,000 for
                                    management improvements; and $95,800 for lead based
                                    paint abatement. The program agreement required all
                                    approved funds to be obligated and the work completed by
                                    December 31, 1996. As of August 13, 1996, the
                                    Commission had unobligated Vacancy Reduction Program
                                    funds of $272,183. The Housing Commission had
                                    obligated funds of only $173,617: $132,917 for repairs and

                                            Page 3                                  97-CH-202-1002
Finding 1



                            $40,700 for management improvements. No funds had
                            been obligated or used for lead based paint abatement. The
                            Commission did not have plans to obligate any more funds
                            or complete any more work items by December 31, 1996.
                            Under the terms of the grant, on December 31, 1996 all
                            unobligated funds are required to be returned to HUD.

                            The Commission repaired 31 of the planned 35 units. The
                            other four units were scattered site units that were beyond
                            economical repair. The total cost of the repairs on the 31
                            units was $132,917 or an average of $4,287 per unit. The
                            average cost was much less than the estimated average of
                            $8,000 the Commission used in its Vacancy Reduction
                            Program application. The units did not require major
                            rehabilitation work with the exception of roof replacements
                            that cost a total of $45,678. The other work was for routine
                            maintenance and unit preparation items like cleaning,
                            boarding, painting and minor repairs.            Since the
                            Commission did not have detailed documentation to backup
                            its estimated cost of repairs, we could not determine why
                            the actual cost of repairs was significantly less than the
                            grant application estimate.

                            The Commission's Executive Director said he did not fully
                            understand the program. He thought the money not used on
                            vacancy reduction work could be used for other purposes
                            like routine unit preparation of units not listed under the
                            Vacancy Reduction Program. According to the program
                            requirements, approved funds can only be used for the work
                            items approved in the agreement with HUD. HUD did not
                            allow any of the Vacancy Reduction funds to be spent on
                            items not authorized by the agreement.

                            The Commission did not complete the management
                            improvements that included an energy audit and hiring a
                            consultant to administer the Vacancy Reduction Program.
                            The Director said he wanted to use the energy audit funds
                            to install individual meters, but he never requested a
                            revision to the agreement. He said he did not hire a
 The Commission Did Not     consultant because he believed HUD would not approve of
 Include Lead Based Paint   the consultant that he planned to hire.
 Abatement In Its
 Comprehensive Grant
 Plans


97-CH-202-1002                      Page 4
                                                                                   Finding 1



HUD's regulations require the Housing Commission to test its units for lead based paint and
abate the paint in those units that test positive. The regulations also require a Commission
to prioritize the abatement within its Comprehensive Modernization Program. The
Commission completed its lead based paint testing in 1994. The test results indicated that
200 out of 355 units required lead based paint abatement.

                                The Commission estimated it would cost approximately
                                $4,239 to abate each of the first 42 units it had targeted for
                                abatement. Applying this estimate to all 200 units, it will
                                cost the Commission about $847,800 to complete its lead
                                based paint abatement. The Acting Director of Public
                                Housing said HUD requires a Housing Commission to do
                                lead based paint abatement as soon as practicable. The
                                Code of Federal Regulations requires an abatement program
                                to be prioritized within a commissions Comprehensive
                                Modernization Program.

                                HUD approved $781,069 for the Commission's 1996
                                Comprehensive Grant Program. The Commission did not
                                prioritize lead based paint abatement in the program.
                                Additionally, in its proposed budget submitted to HUD on
                                July 12, 1996, the Commission did not include any amounts
                                for lead abatement. The budget, included the following
                                non-urgent items totalling $413,107: a new administration
                                building, learning center staff, replacement sewer lines, and
                                privacy dividers. As of September 20, 1996, the budget had
                                not been approved by HUD.

                                The Commission's overestimation of its requirement for
                                vacancy reduction funds and its attempt to save the funds
                                and use them in other areas, needlessly tied up $272,183
                                that could have been used to improve the living conditions
                                of residents at one of HUD's Public Housing Authorities or
                                Commissions. Further, the failure to use the Vacancy
                                Reduction Program funds allotted for lead based paint
                                abatement and to prioritize abatement in its Comprehensive
                                Modernization Program, put the Commission's lead based
                                paint abatement program behind and needlessly subjected
                                its tenants to a hazard.




                                         Page 5                                   97-CH-202-1002
Finding 1



Auditee Comments   Excerpts from the Executive Director's comments on our
                   draft finding follow. Appendix A contains the complete
                   text.

                   The Commission is not content with the finding pertaining
                   to the Vacancy Reduction Program.

                   From November 1994 to May 1995, the Commission
                   strongly believes that it was making progress towards
                   reaching the goals of its Vacancy Reduction Program.
                   From May 1995 through the present, the Commission has
                   made little progress towards achieving the goals of the
                   Program due to a very serious micro-management problem
                   of the Program by the Grand Rapids HUD Area Office.

                   Problems with HUD pertaining to the Vacancy Reduction
                   Program have arisen, in part, due to the HUD Grand Rapids
                   Office not familiarizing itself with the purposes and goals
                   of the program as proposed by the Muskegon Heights
                   Housing Commission in its grant application.

                   The Commission is not content with the finding pertaining
                   to lead based paint. In May 1995, the Commission
                   proposed to HUD an action plan to abate lead based paint
                   in East Park Manor. Although HUD officials did not object
                   to the plan, they had some concern about costs for the
                   abatement program and qualifications of vendors that would
                   be associated with the program. In several letters to HUD
                   officials, the Commission explained that according to state,
                   as well as new Federal regulations pertaining to lead based
                   paint in dwellings, the lead based paint in the apartments in
                   East Park Manor do not pose a threat to the health and
                   safety of residents of East Park manor.

                   In the letters, the Commission has stated that if HUD feels
                   the lead based paint does pose a threat (and I have said that
                   it doesn't) the county health department should be requested
                   to make the determination. HUD officials have not
                   requested that I call the health department pertaining to this
                   matter.




97-CH-202-1002              Page 6
                                                                      Finding 1



OIG Evaluation of   We did not find that the HUD Grand Rapids Area Office
Auditee Comments    managed the Commission's Vacancy Reduction Program
                    differently from how they managed other Commissions'
                    programs. The Executive Director said in his comments
                    that the HUD Grand Rapids Office was not familiar with the
                    Commission's proposed goals as presented in the grant
                    application. Since the Commission and HUD signed a
                    grant agreement, the goals in the application are immaterial.
                    The purpose and goals in the grant agreement are clear and
                    comprehensible.

                    According to the grant agreement, the Commission was
                    required to abate the lead based paint in the units that were
                    repaired. The Commission did not do any abatement of the
                    lead based paint in the units.

                    The Executive Director said in his comments that in his
                    opinion, the lead based paint does not pose a threat. The
                    Director's opinion is not backed by any studies. It is the
                    responsibility of the Commission to get a study done to
                    determine whether its units need lead based paint abatement
                    and how best to get the paint abated. The Commission has
                    already determined that 200 of its units need lead based
                    paint abatement. The Deputy Assistant Secretary for Public
                    and Assisted Housing told the Commission on July 26,
                    1996 that the Commission was in default of its Vacancy
                    Reduction Program agreement with HUD and was not in
                    compliance with the lead based paint abatement
                    requirements.



Recommendations     We recommend that the Grand Rapids Director of Public
                    Housing:

                    1A.    Requires the Commission to request an extension
                           from the Deputy Assistant Secretary for Public
                           Housing to use $95,800 of its Vacancy Reduction
                           Program agreement funds to abate lead based paint
                           in the 31 units repaired under the agreement. If the
                           extension is granted, ensure the Commission
                           immediately uses the funds to abate lead based paint
                           according to its agreement with HUD.




                             Page 7                                  97-CH-202-1002
Finding 1



                 1B.   Reviews the 1996 budget for the Comprehensive
                       Grant Program and revises it to divert planned non
                       urgent expenditures to the lead based paint
                       abatement program to the maximum amount
                       possible.

                 1C.   Closely monitors the Commission to ensure that it
                       complies with HUD's lead based paint abatement
                       requirements.

                 1D.   Establishes policies, procedures and controls that
                       assure HUD's program staff validates the
                       reasonableness of planned vacancy reduction work
                       contained in applications submitted to HUD.




97-CH-202-1002          Page 8
                                                                                        Finding 2




   The Commission's Tenant Eviction Process
           Was Not Economical
The Muskegon Heights Housing Commission paid unnecessary amounts to a legal firm for tenant
eviction services. The Commission paid the firm to perform some services that should have been
done by the Commission's staff. Additionally, the Commission did not have documentation to
support its procurement of eviction legal services. As a result, the Commission was not making
the best use of its resources and HUD and the Commission lack assurance full and open
competition were used to select the provider of the eviction services.



                                    Section 201 of the Annual Contributions Contract requires
 HUD's Requirements
                                    the Commission to at all times operate each project in such
                                    a manner as to promote serviceability, efficiency, economy,
                                    and stability.

                                    Regulation 24 CFR 85.36(12)(c)(1) requires all
                                    procurement to be conducted in a manner that provides full
                                    and open competition. Section 85.36(b)(9) requires a
                                    commission to maintain records sufficient to detail the
                                    significant history of a procurement. These records will
                                    include but are not necessarily limited to the following:
                                    rationale for the method of procurement; selection of
                                    contract type; contractor selection or rejection; and the basis
                                    for the contract price.

                                    The Housing Commission paid excessive amounts for
 Unnecessary Amounts
                                    tenant eviction legal services.        During 1996, the
 Were Paid For Legal
                                    Commission's legal costs for 355 units were $24,838 or $70
 Services
                                    per unit. Another Commission of comparable size and
                                    location that also used a local law firm for its tenant
                                    eviction services, paid $42 per unit. At $42 per unit the
                                    Muskegon Commission would have paid $14,070.
                                    Muskegon's costs were excessive because it allowed its law
                                    firm to provide and charge for services that should have
                                    been done by the Commission's staff. The law firm was
                                    copying leases, calculating the amounts owed by tenants,
                                    and preparing notices to quit. The Commission had the
                                    staff that should have been doing the work. The
                                    Commission's Director agreed the work could be done by
                                    the Commission's staff.

                                             Page 9                                   97-CH-202-1002
Finding 2



                          The Muskegon Heights Housing Commission did not have
 The Commission Did Not
                          documentation to support that open competition was
 Have Proper
                          followed when procuring the services of a law firm for
 Documentation
                          evictions. The Commission also did not have a written
                          contract that detailed the cost and scope of the services
                          provided.

                          The Commission's Executive Director did not know how
                          the law firm was selected. The Director said the law firm
                          was providing legal services when he became the Director
                          four years ago and he kept using them.



Auditee Comments          The Commission is not content with the finding. However,
                          the Commission is pleased to learn the approximate cost
                          that other housing authorities are paying for legal fees
                          pertaining to evictions is $42 per unit.

                          My concern with the finding is that it includes costs for
                          non-eviction services for such things as: legal council and
                          opinions pertaining to personnel matters, agreements and
                          options, and disputes and problems with contractors. The
                          finding also includes costs for interpretation of HUD
                          policies, rules and regulations such as: the Annual
                          Contributions Contract, HUD's "One Strike and You're Out"
                          Policy, rent collection policy, and grievance procedures.

                          The cost for legal services pertaining to non-eviction legal
                          matters is approximately 25 percent of the total that we pay
                          the current law firm and equals approximately $6,210.
                          Therefore, the cost for eviction services would be $52 per
                          unit versus $42 paid by other housing authorities.

                          The Executive Director, along with other Commission staff,
                          will establish internal controls and procedures to reduce the
                          cost for legal services pertaining to evictions. On or before
                          March 31, 1997, the Commission will solicit proposals for
                          tenant eviction services using full and open competition.
                          On or before December 31, 1996, the Executive Director,
                          as well as other Commission staff, will review, with the
                          Commission's present law firm, procedures and ways the
                          Commission can reduce tenant eviction services costs to
                          approximately $42 per unit.



97-CH-202-1002                    Page 10
                                                                      Finding 2




OIG Evaluation of   The documentation we reviewed indicated the legal fees of
Auditee Comments    $24,838 were for tenant eviction services. The Executive
                    Director mentioned in his comments that approximately 25
                    percent of $24,838 were for other legal matters. The
                    Director based this on his Assistant Director's memorandum
                    of October, 1996 that stated that it was the Assistant
                    Director's belief that at least 25 percent of the $24,838 was
                    for other services than eviction. The Commission did not
                    provide any documentation to substantiate the belief.

                    The Director plans actions that should correct the conditions
                    reported in this finding when the actions are fully
                    implemented.


Recommendations     We recommend that the Grand Rapids Director of Public
                    Housing assures the Housing Commission:

                    2A.    Solicits proposals for tenant eviction services using
                           full and open competition.

                    2B.    Immediately stops having the law firm perform
                           routine tasks that can be accomplished by the
                           Commission's staff.




                            Page 11                                  97-CH-202-1002
Finding 2




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97-CH-202-1002                   Page 12
                                                                                       Finding 3




    The Housing Commission Did Not Prepare
           Timely Financial Reports
The Muskegon Heights Housing Commission did not submit its independent audits, operating
budgets, and other financial information reports to HUD timely. As a result, HUD did not have
adequate information to assess the Commission's financial condition, and the Commission was
prevented from withdrawing Federal funds to meet its obligations during the times it did not have
an approved budget.



                                     The Office of Management and Budget Circular A-128,
 HUD's Requirements
                                     Audits of State and Local Governments, paragraph 9(f)
                                     requires a housing commission to send an audit report to
                                     HUD within 30 days after the completion of the audit, but
                                     no later than one year after the end of the audit period. The
                                     audit must be conducted by an independent auditor and be
                                     done according to generally accepted government auditing
                                     standards.

                                     The Annual Contributions Contract, Section 407, requires
                                     a housing commission to submit a proposed operating
                                     budget not later than 90 days before the start of the next
                                     fiscal year. Section 407 also says a housing commission
                                     cannot use Federal funds to pay operating expenditures
                                     without an approved operating budget.

                                     HUD Handbook 7510.1, Public and Indian Housing Low-
                                     Rent Technical Accounting Guide, and HUD Handbook
                                     7475.1, The Financial Management Handbook, require a
                                     commission to submit financial reports to HUD within 45
                                     days following the end of the period for which the report is
                                     prepared.

                                     The Muskegon Heights Housing Commission did not get its
 Independent Audits Were
                                     annual independent audits of its operations completed and
 Not Timely
                                     submitted to HUD in a timely manner. The audit for the
                                     year ended March 31, 1994 was required to be submitted to
                                     HUD by March 31, 1995; however, the Commission did not
                                     get the audit completed and submitted to HUD until April
                                     16, 1996, 382 days late. The audit for the year ended
                                     March 31, 1995 was due March 31, 1996. As of August

                                             Page 13                                  97-CH-202-1002
Finding 3



                    1996, an independent auditor had not started the audit and
                    it was already 151 days late.

                    The Executive Director said for the last two years he
                    advertised in the local newspaper for auditors to submit
                    bids, but he did not receive any bids. The Director said he
                    then delayed before taking action to retain the auditor who
                    performed the previous audit. As a result both audits were
                    extremely late. To avoid future delays, the Commission
                    needs to improve its method to obtain independent audits.
                    For example, the Commission could sign a multi-year
                    contract with its current auditor, as allowed by HUD. The
                    Commission could also maintain a list of independent
                    auditors and send each of them an invitation to submit a
                    bid.

                    The Housing Commission has not submitted a yearly
 Budgets Were Not
                    operating budget in a timely manner since 1992. The
 Submitted Timely
                    delays have ranged between 80 and 231 days.

                    For the fiscal year that started April 1, 1995, the
                    Commission submitted its proposed budget on July 27,
                    1995, 207 days late. The budget should have been
                    submitted by December 31, 1994. For the year that started
                    April 1, 1996, the Commission submitted its final proposed
                    budget to HUD on August 22, 1996, 231 days late. HUD
                    has 45 days to approve or disapprove the budget. As of
                    August 31, 1996, 240 days after the start of the fiscal year,
                    the budget had not been approved by HUD and the
                    Commission was operating without an approved budget.
                    Consequently, the Commission could not withdraw any
                    Federal funds to help meet its fiscal requirements. The
                    Commission had to use its rental income and non-Federal
                    funds to meet its expenditures. The Commission's Director
                    said if he did not shortly have an approved budget he would
                    have to lay off staff. Housing commissions need to ensure
                    they have an approved budget so they can efficiently and
                    effectively use available funds to provide decent, safe, and
                    sanitary housing for low and moderate income tenants.

                    The Executive Director said the budgets were late because
                    he did not start preparing them until after the end of the
                    previous fiscal year. The end of the Fiscal Year was
                    already 90 days late. He said he did not have adequate staff


97-CH-202-1002              Page 14
                                                                            Finding 3



                          to start the budget process any sooner. He had to rely on
                          his fee accountant and a consultant to prepare the budget.
                          However, in 1994, HUD had approved hiring a full time
                          accountant for the Commission. The Director said he will
                          hire an accountant after a new accounting system is
                          installed by Memory Lane Systems. The Director said the
                          new system will be fully installed and operational by
                          January 31, 1997.

                          The Housing Commission did not submit its required
 Financial Reports Were
                          financial information reports to HUD in a timely manner.
 Not Timely
                          Since 1991 the following reports were all submitted
                          between 50 and 103 days late: Statement of Income and
                          Expense and Changes in Accumulated Surplus; Statement
                          of Operating Receipts and Expenditures; Analysis of Non-
                          routine Expenditures; Computation of Payments in Lieu of
                          Taxes; Report of Tenants Accounts Receivable; and
                          Balance Sheet for Section 8 and Public Housing.

                          The delays were caused because the Housing Commission
                          did not promptly send its financial information to the fee
                          accountant for the preparation of the reports. The Director
                          said the problem would be solved when the Commission
                          hires a full time accountant.



Auditee Comments          Excerpts from the Executive Director's comments on our
                          draft finding follow. Appendix A contains the complete
                          text.

                          The Commission is content with the finding. The corrective
                          action to be taken will be to follow advice and
                          recommendations outlined in the audit findings.

                          The Commission will improve its policy and procedures to
                          obtain independent audits by entering into a multi-year
                          contract with its current auditor. It will also establish and
                          maintain a list of independent auditors and send each of
                          them an invitation to submit a proposal for audit services

                          The Executive Director will start preparing the fiscal budget
                          so that it will be submitted to HUD by December 31 of each
                          year. The Commission expects to hire a full-time



                                  Page 15                                  97-CH-202-1002
Finding 3



                    accountant to help with preparation of the budget and other
                    accounting tasks on or before January 31, 1997.

                    The Executive Director, Assistant Director, as well as an
                    accountant when hired, will establish internal procedures
                    and controls to insure that financial reports to HUD, as well
                    as other governmental agencies, will be submitted on a
                    timely basis. Until an accountant is hired, the Executive
                    Director, the Assistant Director and the Director of Housing
                    Programs will establish internal procedures and controls so
                    as to get reports to the fee accountant and others on a timely
                    basis.



OIG Evaluation of   The auditee plans actions that should correct the conditions
Auditee Comments    reported in this finding when the actions are fully
                    implemented.


Recommendations     We recommend that the Grand Rapids Director of Public
                    Housing assures the Housing Commission:

                    3A.    Establishes procedures and controls to accomplish
                           independent audits on a timely basis.

                    3B.    Establishes procedures and controls to ensure the
                           budget preparation process is started in sufficient
                           time to allow the budget for the next fiscal year to
                           be submitted to HUD 90 days before the end of the
                           current fiscal year.

                    3C.    Immediately hires a full time accountant.




97-CH-202-1002              Page 16
                                                                                       Finding 4




Control Over Non-Expendable Assets Was Not
                 Adequate
The Muskegon Heights Housing Commission did not follow its own inventory policy and HUD's
requirements to protect its non-expendable equipment. The Commission did not conduct annual
physical counts of its equipment and supplies and did not routinely update its property records.
The Commission's Director said the Commission did not take or reconcile inventories because
he did not believe inventories were important. To help detect and prevent misuse or loss of
resources, it is important for the Authority to take annual inventories and maintain accurate
records.



                                    HUD Handbook 7510.1, Low-Rent Housing Accounting
 HUD's Requirements
                                    Handbook and the Public and Indian Housing Low-Rent
                                    Technical Accounting Guide, require a housing commission
                                    to keep equipment records that include an asset's cost and
                                    a sufficient description to identify it for an annual physical
                                    inventory.

                                    The Commission's Policy requires its staff to complete a
 Housing Commission's
                                    physical inventory of all Commission property located in
 Policy
                                    offices, maintenance shops, garages and dwelling units by
                                    the last day of February of each year. The policy also
                                    requires the Commission to send a completed physical
                                    inventory to the fee accountant by the second week of
                                    March for reconciliation to the property records.

                                    The Muskegon Heights Housing Commission had not taken
 Annual Inventories Were
                                    an annual inventory of its physical assets in over four years.
 Not Taken And Proper
                                    The Commission took its last inventory in 1992. The
 Records Were Not Kept
                                    Commission's fee accountant kept property ledgers;
                                    however, the ledgers were not updated routinely. The fee
                                    accountant was not always informed when equipment was
                                    purchased, disposed of, or replaced.

                                    The Commission also maintained property records in the
                                    form of individual property cards for each item. The cards
                                    contained specific information relating to each item of
                                    equipment including description, date of purchase, cost,
                                    identification number, and physical location. However, the
                                    Commission did not routinely update the card files when

                                             Page 17                                  97-CH-202-1002
Finding 4



                   new equipment was purchased. For example, property
                   ledgers show the Commission purchased three ranges in
                   December 1995. The Commission did not have individual
                   cards to show the cost of each item, its identification
                   number and its physical location.

                   The Commission's general ledger showed the Commission
                   had $523,916 in non-expendable equipment. However, the
                   amount was last reconciled to an inventory in 1992, and, as
                   previously stated, was not routinely updated. An annual
                   inventory that accurately counts and tracks non-expendable
                   equipment helps protect against fraud, waste and abuse.

                   The Commission's Executive Director said the Commission
                   did not take annual physical inventories and always keep
                   accurate inventory records because he did not consider
                   inventories were important and he was concentrating on
                   areas, such as; processing grant applications and
                   modernization work. However, the Director agreed that in
                   the future to have proper accountability and control, all
                   items should be identified and physical inventories taken.



Auditee Comments   Excerpts from the Executive Director's comments on our
                   draft finding follow. Appendix A contains the complete
                   text.

                   The Commission is content with the finding, but disagrees
                   strongly with the reason stated in the report as to why
                   annual inventories were not taken and proper records were
                   not kept.

                   The Executive Director, as well as other Commission staff,
                   will establish internal controls and procedures to insure that
                   inventory of non-expendable assets will be completed
                   before the end of each fiscal year. On or before January 31,
                   1997, an inventory of non-expendable equipment should be
                   completed.

                   The reason inventory was not taken had little to do with the
                   Executive Director processing grants. The reasons had
                   more to do with absenteeism in the maintenance department
                   and the continued priority of maintaining high occupancy
                   and keeping units safe and sanitary for residents.


97-CH-202-1002             Page 18
                                                                     Finding 4




OIG Evaluation of   The Executive Director said the Commission will establish
Auditee Comments    procedures and controls to ensure inventories are
                    completed. However, the Commission also needs to
                    establish and implement procedures to routinely update
                    inventory records and to reconcile the physical inventories
                    to inventory records and the general ledger.

                    We believe absenteeism in the maintenance department and
                    a priority to maintain high occupancy and safe and sanitary
                    units is not an adequate reason to not take an inventory for
                    four years in a row.


Recommendations     We recommend that the Grand Rapids Director of Public
                    Housing assures the Housing Commission:

                    4A.    Establishes and implements procedures to routinely
                           update inventory records.

                    4B.    Establishes and implements controls to perform
                           annual inventories.

                    4C.    Establishes and implements policies, procedures and
                           controls to reconcile annual physical inventories to
                           inventory records and the general ledger.




                            Page 19                                 97-CH-202-1002
Finding 4




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97-CH-202-1002                   Page 20
Internal Controls
In planning and performing our audit, we considered the internal controls of the management of
the Muskegon Heights Housing Commission in order to determine our auditing procedures and
not to provide assurance on internal controls. Internal controls consist of the plan of organization
and methods and procedures adopted by management to ensure that resource use is consistent
with laws, regulations, and policies; that resources are safeguarded against waste, loss, and
misuse; and that reliable data are obtained, maintained, and fairly disclosed in reports.



                                      We determined that the following internal controls were
 Relevant Internal
                                      relevant to our audit objectives:
 Controls
                                      •   Management Policies, Procedures, and Practices

                                      •   Safeguards over assets

                                      •   Accounting system

                                      We assessed all the relevant controls identified above.

                                      It is a significant weakness if internal controls do not give
                                      reasonable assurance that resource use is consistent with
                                      laws, regulations, and policies; that resources are
                                      safeguarded against waste, loss, and misuse; and that
                                      reliable data are obtained, maintained, and fairly disclosed
                                      in reports.

                                      Based on our audit, the followings items are significant
 Significant Weaknesses
                                      weaknesses:

                                      •   Management Policies, Procedures, and Practices. The
                                          Housing Commission did not follow adequate policies,
                                          procedures, and practices to assure: the Commission
                                          followed its Vacancy Reduction Program agreement
                                          (see Finding 1); the tenant eviction process was
                                          economical (see Finding 2); and independent audits,
                                          operating budgets, and other financial information
                                          reports to HUD were prepared timely (see Finding 3).

                                      •   Safeguards Over Assets. The Housing Commission did
                                          not maintain adequate controls over its non-expendable
                                          assets (see Finding 4).




                                               Page 21                                  97-CH-202-1002
Internal Controls




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97-CH-202-1002                      Page 22
Follow Up On Prior Audits
The last OIG audit report (number 90-CH-209-1015, June 14, 1990) on the Muskegon Heights
Housing Commission contained six findings. There were no open findings from that audit, and
none of the findings are repeated in this report.

The Commission's last Independent Accountant's audit report was for the year ended March 31,
1994. It did not contain any findings.




                                           Page 23                               97-CH-202-1002
Follow Up On Prior Audits




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97-CH-202-1002                      Page 24
                                                                                     Appendix A

Auditee Comments
October 7. 1996

Mr. Muhammad M. Akhtar, Senior Auditor
Office of Inspector General
477 Michigan Avenue, Room 1790
Detroit, MI 48226-2592

Dear Mr. Akhtar:

SUBJECT:      Notice of Audit Findings of the Office of Inspector General for Audit, HUD.

With reference to your letter to me dated September 27, 1996, please be advised that we have
reviewed your four (4) findings and our response is the following:

FINDING #3 -         The Housing Commission did not prepare timely financial reports.

                     A. Independent audits were not timely. The Commission is content
                     with the finding. The corrective action to be taken will be to follow
                     advice and recommendations outlined in the audit findings.

                     CORRECTIVE ACTION: The Commission will improve its policy
                     and procedures to obtain independent audits by entering into a multiyear
                     contract with its current auditor. It will also establish and maintain a list
                     of independent auditors and send each of them an invitation to submit a
                     proposal for audit services.

                     B. Budgets were not submitted timely. The Commission is content
                     with the finding. The corrective action to be taken will be to follow the
                     advice and recommendations outlined in the audit findings.




                                             Page 25                                  97-CH-202-1002
Appendix A



Commission Response to
Notice of Audit Findings
October 7, 1996                        Page 2

FINDING #3 -       The Housing Commission did not prepare timely financial reports.
                   (CONTINUED)

                   CORRECTIVE ACTION: The Executive Director will start preparing
                   the fiscal budget so that it will be submitted to HUD by December 31st
                   of each year.

                   The Commission expects to hire a full-time accountant to help with
                   preparation of the budget and other accounting tasks on or before
                   January 31, 1997.

                   C. Financial reports were not timely. The Commission is content
                   with the finding. The corrective action to be taken will be to follow the
                   advice and recommendations outlined in the audit findings.

                   CORRECTIVE ACTION: The Executive Director, Assistant Director,
                   as well as an accountant when hired, will establish internal procedures
                   and controls to insure that financial reports to HUD, as well as other
                   governmental agencies, will be submitted on a timely basis.

                   Until an accountant is hired, the Executive Director, the Assistant
                   Director and the Director of Housing Programs (who is responsible for
                   Section 8 financial reports) will establish internal procedures and
                   controls so as to get reports to the fee accountant and others on a timely
                   basis.

FINDING #4 -       Control of Non-Expendable Assets was not adequate.

                   The Commission is content with the finding, but disagrees strongly with
                   the reason stated in the report as to why annual inventories were not
                   taken and proper records were not kept.




97-CH-202-1002                            Page 26
                                                                                 Appendix A



Commission Response to
Notice of Audit Findings
October 7, 1996                        Page 3

FINDING #4 -       Control of Non-Expendable Assets was not adequate. (CONTINUED)

                   The reason inventory of non-expendable assets was not taken had little
                   to do with the Executive Director processing grants. The reasons had
                   more to do with absenteeism in the Maintenance Department and the
                   continued priority of maintaining high occupancy and keeping units safe
                   and sanitary for residents.

                   When the present director assumed the duties of executive director in
                   June of 1992, the Commission's Public Housing Management
                   Assessment Program score was 30.71.

                   In September 1992, the Board of Commissioners and HUD directed the
                   Executive Director to establish priorities which dealt with:

                   1. removing the Commission from HUD's Troubled/Distressed List
                   through initiatives outlined in a Memorandum Of Agreement.

                   2. reducing vacancies and increasing occupancy.

                   3. reducing incidents of drug-trafficking and drug-related crimes.

                   4. reducing the number of residents behind with their rent.

                   5. reducing costs for energy/utilities.

                   6. obtaining HUD funds to replace roofs and modernize dwelling
                    units.

                   7. improving maintenance services to residents.

                   8. computerizing programs and systems.

                   9. transferring residents to adequate-sized units.

                   10. reactivating the homeownership program.




                                          Page 27                                97-CH-202-1002
Appendix A



Commission Response to
Notice of Audit Findings
October 7, 1996                        Page 4

FINDING #4 -       Control of Non-Expendable Assets was not adequate. (CONTINUED)

                   11. completing an inventory of Commission nonexpendable assets
                      which had not been completed since 1989.

                   12. reducing operating expenses.

                   Since the last inventory of non-expendable assets was completed in
                   1992, the Executive Director has made much progress towards
                   completing the aforementioned goals (also see enclosed "ACTION
                   PLAN for a Distressed/Troubled Housing Authority Goals and
                   Priorities").

                   CORRECTIVE ACTION: The Executive Director, as well as other
                   Commission staff, will establish internal controls and procedures to
                   insure that inventory of non-expendable assets will be completed before
                   the end of each fiscal year (March 31st).

                   On or before January 31, 1997, an inventory of non-expendable assets
                   should be completed.

FINDING #2 -       The Commission's Tenant Eviction Process Was Not Economical.

                   The Commission is not content with the finding. However the
                   Commission is pleased to learn the approximate cost that other housing
                   authorities are paying for legal fees pertaining to evictions is $42 per
                   unit.

                   My concern with the finding is that it includes costs for non-eviction
                   services for such things as legal council and opinions pertaining to:

                   1. personnel matters.

                   2. agreements and options.

                   3. disputes and problems with contractors.




97-CH-202-1002                             Page 28
                                                                                 Appendix A



Commission Response to
Notice of Audit Findings
October 7, 1996                        Page 5

FINDING #2 -       The Commission's Tenant Eviction Process Was Not Economical.
                   (CONTINUED)

                   4. interpretation of HUD policies, rules and regulations such as:

                           a. Annual Contributions Contract.

                           b. HUD's "One Strike and You're Out" Policy.

                           c. rent collection policy and grievance procedures.

                   The cost for legal services pertaining to non-eviction legal matters is
                   approximately 25 percent of the total that we pay the current law firm
                   which equals approximately $6,210. The cost for eviction services
                   would be $52 per unit versus $42 paid by other housing authorities (also
                   see Inter-Office Memo from the Assistant Director dated October 4,
                   1996).

                   CORRECTIVE ACTION: The Executive Director, along with other
                   Commission staff, will establish internal controls and procedures to
                   reduce the cost for legal services pertaining to evictions.

                   On or before March 31, 1997, the Commission will solicit proposals for
                   tenant eviction services using full and open competition.

                   On or before December 31, 1996, the Executive Director, as well as
                   other Commission staff, will review, with the Commission's present law
                   firm, procedures and ways the Commission can reduce tenant eviction
                   services costs to approximately $42 per unit.

FINDING #1 -       The Commission did not follow its Vacancy Reduction Program (VRP)
                   Agreement.

                   A. The Commission is not content with the finding pertaining to the
                    Vacancy Reduction Program.




                                          Page 29                                97-CH-202-1002
Appendix A



Commission Response to
Notice of Audit Findings
October 7, 1996                       Page 6

FINDING #1 -       The Commission did not follow its Vacancy Reduction Program (VRP)
                   Agreement. (CONTINUED)

                   A. Vacancy Reduction Program. (CONTINUED)

                   From November 1994 to May 1995, the Commission strongly believes
                   that it was making progress towards reaching the goals of its Vacancy
                   Reduction Program.

                   From May 1995 through the present, the Commission has made little
                   progress towards achieving the goals of the Vacancy Reduction
                   Program due to a very serious micro-management problem of the
                   program by the Grand Rapids HUD Area Office.

                   In letters to Area HUD Office directors and to staff at HUD
                   Headquarters, the Commission has outlined the problem it feels
                   obstructs administration of the Vacancy Reduction Program.

                   The Commission feels so strongly about its poor working relationship
                   with HUD and the Vacancy Reduction Program that it:

                   1. nearly requested that the program be terminated.

                   2. has requested, on three separate occasions, that the monitoring
                   process of the program be transferred from the Grand Rapids Office
                   to the Detroit Office.

                   Problems with HUD pertaining to the Vacancy Reduction Program have
                   arisen, in part, due to the HUD Grand Rapids Office not familiarizing
                   itself with the purposes and goals of the program as proposed by the
                   Muskegon Heights Housing Commission in its grant application.

                   The Commission would welcome, moreover it hereby requests, that
                   HUD staff in the Grand Rapids Office, Detroit Office and the
                   Washington Office review every letter and correspondence sent by the
                   Executive Director to HUD pertaining to problems with the Vacancy
                   Reduction Program.




97-CH-202-1002                           Page 30
                                                                                Appendix A



Commission Response to
Notice of Audit Findings
October 7, 1996                        Page 7

FINDING #1 -       The Commission did not follow its Vacancy Reduction Program (VRP)
                   Agreement. (CONTINUED)

                   A. Vacancy Reduction Program. (CONTINUED)

                   The Commission believes that if all correspondence pertaining to the
                   Vacancy Reduction Program is carefully read, HUD will reach the
                   conclusion that most of the problems and delays pertaining to the
                   Vacancy Reduction Program are not the fault of the Muskegon Heights
                   Housing Commission.

                   B. The Commission is not content with the finding pertaining to Lead
                    Based Paint.

                   In May 1995, the commission proposed to HUD an action plan to abate
                   lead-based paint in East Park Manor.

                   Although HUD officials did not object to the plan, they had some
                   concern about costs for the abatement program and qualifications of
                   vendors that would be associated with the program.

                   In a series of letters, the Commission has explained why it did not
                   implement a lead-based paint program during 1995 and early 1996. I
                   hope you will review correspondence pertaining to why the
                   Commission did not implement a lead-based paint program at East Park
                   Manor.

                   In several letters to HUD officials, the Commission has presented an
                   action plan to start a lead-based paint abatement program in East Park
                   Manor before the end of 1996. I hope you will read letters pertaining to
                   the action plan.

                   In several letters to HUD officials, the Commission has explained that
                   according to state, as well as new Federal regulations pertaining to lead-
                   based paint in dwellings, the lead-based paint in the apartments in East
                   Park Manor do not pose a threat to the health and safety of residents of
                   East Park manor.




                                          Page 31                                97-CH-202-1002
Appendix A



Commission Response to
Notice of Audit Findings
October 7, 1996                         Page 8

FINDING #1 -         The Commission did not follow its Vacancy Reduction Program (VRP)
                     Agreement. (CONTINUED)

                     B. Lead Based Paint. (CONTINUED)

                     In the letters, the Commission has stated that if HUD feels the lead-
                     based paint does pose a threat (and I have said that it doesn't), the
                     county health department should be requested to make the
                     determination. HUD officials have not requested that I call the health
                     department pertaining to this matter.

                     CORRECTIVE ACTION: The Commission has requested an
                     extension to spend the remainder of its vacancy reduction funds to meet
                     goals and priorities of the program. As of this date, the Commission has
                     not heard from HUD on this matter.

                     The Commission will request HUD program staff to review the goals
                     and objectives of the Vacancy Reduction Program and validate the
                     reasonableness of planned vacancy reduction work contained in the
                     application submitted to HUD and a subsequent budget revision.

I understand that once you receive the responses to the findings submitted herewith, you
would like to meet with Commission staff on October 18, 1996. The date is satisfactory and I
would like to recommend 2:00 p.m.

I wish to thank you and Mrs. Judith Storrs for the suggestions and recommendations you
made while on site to help improve the operation and efficiency of the Muskegon Heights
Housing Commission, as well as where we should seek help to overcome the problems that
we have with HUD.

                                Sincerely,



                                Joe L. Mattox
                                Executive Director

C: Joyce E. Thomas, Assistant Director
   Lindsey Reames, Director, Grand Rapids HUD Area Office



97-CH-202-1002                               Page 32
                                                                                                   Appendix A



INTER-OFFICE MEMO                         MUSKEGON HEIGHTS HOUSING COMMISSION
                                  615 East Hovey Avenue
                                     Muskegon Heights, Mi 49444



DATE:         October 4, 1996

TO:          Joe L. Mattox, Executive Director

FROM:        Joyce E. Thomas, Assistant Director

SUBJECT: OIG Finding No.2/Commission's Tenant Eviction Process Was Not
       Economical

------------------------------------------------------------------------------------------------------------------
--

In reference to the above mentioned subject the amount billed
for legal services was not limited to tenant evictions only.

$24.838.00 is not an excessive amount for legal services based on the number of evictions
and personal services that was rendered on behalf of the Housing Commission. It is my belief
that at least 25 percent of the $24,838 was for other services than evictions.

Sure, a staff person could do the paperwork for the evictions, but this is very time consuming
considering the staff person has a multitude of other responsibilities that must be addressed.

Since I have been employed with the Muskegon Heights Housing Commission, it is not
known to me that we ever used a competitive process in the selection of any law firm.




                                                      Page 33                                       97-CH-202-1002
Appendix A




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97-CH-202-1002                   Page 34
                                                                             Appendix B

Distribution
Secretary's Representative, Midwest
Director, Public Housing Division, Grand Rapids Area Office (2)
State Coordinator, Michigan State Office (2)
Director, Accounting Division, Midwest
Field Comptroller, Midwest
Assistant General Counsel, Midwest
Public Affairs Officer, Midwest
Assistant to the Deputy Secretary for Field Management, SC (Room 7106)
Acquisitions Librarian, Library, AS (Room 8141)
Chief Financial Officer, F (Room 10166) (2)
Deputy Chief Financial Officer for Operations, FO (Room 10166) (2)
Comptroller/Audit Liaison Officer, PF (Room 4122) (3)
Director, Office of Lead Based Paint Abatement and Poisoning Prevention, (Room B-133
   HUD Building) (2)
Director, Modernization Division, PCR (Room 4130) (2)
Associate General Counsel, Office of Assisted Housing and Community Development, GC
  (Room 8162)
Assistant Director in Charge, U.S. GAO, 820 1st St. NE, Union Plaza, Building 2, Suite
  150, Washington DC, 20002 (2)




                                          Page 35                             97-CH-202-1002